Privacy Policy

Effective day 25 May 2018

Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information. If you are a visitor to an Ablio Website or a customer of an Ablio Service or a provider of services to Ablio, then except as expressly set forth below, this Privacy Policy applies to your use of such Website or Service.

As used in this Privacy Policy, “Ablio” “us” and “we” refers to Ablio S.r.l. and its affiliates, including without limitation Ablio LLC. The “Websites” means Ablio’s websites (including without limitation www.ablio.com, www.ablioconference.com, www.ablio.it, www.conferencewifi.com and any successor URLS, mobile or localised versions and related domains and subdomains), and the “Services” means Ablio’s interpreting services and products, applications and services, in each case in whatever format they may be offered now or in the future. The Websites and Services are collectively referred to herein as the “Offerings.”

This Privacy Policy covers the information we collect about you when you use our products or services, or otherwise interact with us (for example, by attending our events), unless a different policy is displayed.

This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

Where we provide the Services under contract with an organisation (for example your employer) that organization controls the information processed by the Services. For more information, please see Notice to End Users below.

1. What information we collect about you

We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Registration and Contact Information. We collect information about you when you register to use the Services and otherwise provide contact information to us via email, mail, or through our Offerings. This information you provide may include your username, first and last name, email address, mailing address or phone number.

Payment Information. When you purchase the Services, we will also collect transaction information, which may include your credit card information, billing and mailing address, and other payment-related information. We describe how Payment Information may be collected and processed in Chapter 4.

Technical, Usage and Location Information. We automatically collect information on how you interact with the Offerings, such as the IP address from which you access the Offerings, date and time, information about your browser, operating system and computer or device, the type, size and filenames of attachments you upload, the Services pages viewed and items clicked. We may also collect location information, including location information automatically provided by your computer or device in order to approximate your location to provide you with a better Service experience. We use cookies and similar technologies to collect some of this information.

Session recordings. All your conversation and sessions handled within our Services by our interpreters are recorded. We describe how the Session Recordings are collected and processed in Chapter 5.

Information you provide through our support channel. The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.

Third Party Platforms. We may collect information about you and your activities when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites.

Other Information. We may collect other information from you that is not specifically listed here. Other users of our Services may provide information about you when they submit content through the Services. For example, an administrator may provide your contact information when they designate you as the billing or technical contact on your company’s account; if you create an account or log into the Services using your Google credentials, we receive your name and email address as permitted by your Google profile settings in order to authenticate you. We will use any such information in accordance with this Privacy Policy or as otherwise permitted by you.

Cookies and Other Tracking Technologies. Ablio and our third-party partners, such as our providers of customer support tools, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to collect some of the above described information. recognize you across different Services and devices. We honour do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place. It’s also important to note that we do not allow third party behavioural tracking. For more information, please see our Cookie Policy.

2. How we use information we collect

We use your information in the following ways:

• To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functions of the Offerings (for example, by remembering your information so that you will not have to re-enter it during this or subsequent visits)
• To process your inquiries and otherwise deliver customer service
• To process your payments, we share and use Payment Information as described in Chapter 4 (Payment Information);
• To control unauthorised use or abuse of the Offerings and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal
• To analyse trends, administer or optimise the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole
• To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in Chapter 7 (How to access and control your information)
• To manage operation connected to your status of service provider
• To deliver you advertising, including by serving and managing ads on the Offerings or on third party sites and to tailor ads based on your interests and browsing history. Please see Chapter 7 (How to access and control your information) for additional information on how to manage the ads you see
• To satisfy a legitimate interest from us (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests
• In the manner described to you at the time of collection or as otherwise described in this Privacy Policy
• With your consent: we use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

3. How we share information we collect with Third Parties

We do not sell or trade your personal information to third parties.

We share your personal information with our website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential and therefore adhere to this Privacy Policy, in the following limited circumstances:

• The information strictly related to the execution of your service request is shared with our interpreter appointed to the task, such as your name, your telephone number, the telephone numbers of your counterparts in the call. Our interpreters may be independent contractors of our companies, therefore for the purpose of this Privacy Policy they may be considered as “third parties”. The protections of this privacy policy apply to the information we share in these circumstances: all our interpreters are bound to maintain strict confidentiality about your information and any information discussed during their interpreting sessions. For more information, please see our Standards of Practice.
• We may share your personal information with third-party service providers (“processors”) to permit such parties to provide services that help us with our business activities, which may include assisting us with the marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functions of the offerings, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings (such as MailChimp), for handling several customer relationship functions like instant chatting (such as Intercom), for handling our cloud telecommunications (such as Twilio). These third-party service providers are just data or meta-data processors of the information and the protections of this Privacy Policy apply to the information we share in these circumstances, as also described in such providers own Privacy Policies (for MailChimp: mailchimp.com/legal/privacy. For Intercom: www.intercom.com/terms-and-policies#privacy; for Twilio: www.twilio.com/legal/privacy/developer).
• We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process or enforceable governmental request, enforce a Customer Agreement, including investigation of potential violations thereof, or protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law.
• We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues.
• We may share your personal information with our business partners who offer a service to you jointly with us: for example a service partner which will integrate its onsite services with our online solutions
• We may share your Payment Information to process your payments, as further described in Chapter 4 (Payment Information);
• We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets.
• We may share your personal information with a third party if we have your consent to do so.

4. Payment Information

When you make a purchase on the Offerings, any credit card information you provide as part of your Payment Information is collected and processed directly by our payment processor Stripe through their Stripe Checkout service. We never receive or store your full credit card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with their own Privacy Policy here: stripe.com/us/checkout/legal.

5. Session Recordings

When an interpreting service session is held by you on the Offerings, it is recorded and stored on our secure servers for the following thirty days before being automatically deleted. During such period from the service dashboard of our Offerings you have the possibility to re-listen to it, download it on your own personal devices or immediately delete it.

When an interpreting service session is held by you on the Offerings, it is recorded and stored on our secure servers for the following thirty days before being automatically deleted. During such period from the service dashboard of our Offerings you have the possibility to re-listen to it, download it on your own personal devices or immediately delete it.

6. How we store and secure information we collect

We use data hosting service providers in the United States and Germany to host the information we collect, and we use technical measures to secure your data.

The security of your personal information is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information. We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs. Further, we have implemented reasonable physical, electronic, and procedural safeguards designed to protect personal information about you. When you enter sensitive information (such as your password), we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. For more information, please see our Security Policy

7. How to access and control your information

You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format.

Below, we describe the tools and processes for making these requests. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. Where the Services are administered for you by an administrator (see “Notice to End Users” below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, your billings and invoices related to the purchases you did so far cannot be deleted since we need to keep records of transactions for administration and tax compliant purposes for a certain number of years.

• Access and update your information. Our Offerings give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account and search for content containing information about you.
• Deactivate your account. If you no longer wish to use our Services, you or your administrator may be able to deactivate your Services account by sending a request by email at support@ablio.com.
• Delete your account and your information. You can ask us to delete your account and your related information by sending a request by email at support@ablio.com. By doing so we’ll not be anymore able to provide certain features of the Offerings to you.
• Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications. Please note, however, that you may be unable to opt-out of certain service-related communications.
• Blocking Cookies. You can remove or block certain cookies using the settings in your browser but the Offerings may cease to function properly if you do so. For more information, please see our Cookie Policy.
• Data portability. Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Should you request it by sending a request by email at support@ablio.com, we will provide you with an electronic file of your information.

If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

8. How we transfer information we collect internationally

We may from time to time transfer your personal information to other countries and make it accessible to our parents, subsidiaries, affiliates and third party service providers internationally. We will protect your personal information in accordance with this Privacy Policy wherever it is processed.

9. Other important privacy information

Notice to End Users

Many of our Offerings are intended for use by organizations. Where the Offerings are made available to you through an organization (e.g. your employer), that organization is the administrator of the Offerings and is responsible for the accounts over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.

Administrators are able to:

• require you to reset your account password;
• restrict, suspend or terminate your access to the Services;
• access information in and about your account;
• access or retain information stored as part of your account;
• install or uninstall third-party apps or other integrations

In some cases, administrators can also:

• restrict, suspend or terminate your account access;
• change the email address associated with your account;
• change your information, including profile information;
• restrict your ability to edit, restrict, modify or delete information.

Please contact your organization or refer to your administrator’s organizational policies for more information.

Our policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

Data protection officer

Our appointed Data Protection Officer is mr. Piergiorgio Fiandanese, who can be reached at giorgio.fiandanese [at] ablio.com email address.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We will also keep prior versions of this Privacy Policy in an archive for your review. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

10. Contact Us

Your information is controlled by Ablio S.r.l. and Ablio LLC. If you have questions or concerns about how your information is handled, please direct your inquiry to support@ablio.com or using the information below.